Secondary service connection
Migraine secondary to a back condition: BVA grant rates and what wins
From 2017 to 2026, the Board of Veterans' Appeals decided migraine claimed as secondary to a back condition in 364 decisions. It granted the issue in 18.4% of them, below the 30.7% grant rate for all migraine issues, denied it in 14.0%, and remanded it in 66.8%. Counting only decisions on the merits, 56.8% were granted.
Decisions
364
2017–2026
Granted
18.4%
All migraine: 30.7%
Granted on the merits
56.8%
Granted ÷ (granted + denied)
Remanded
66.8%
Denied: 14.0%
See all migraine decisions, direct and secondary.
Migraine secondary to a back condition: outcomes by year
| Year | Decisions | Granted | Denied | Remanded |
|---|---|---|---|---|
| 2017 | 23 | 8.7% | 34.8% | 52.2% |
| 2018 | 27 | 7.4% | 22.2% | 70.4% |
| 2019 | 60 | 23.3% | 20.0% | 55.0% |
| 2020 | 32 | 21.9% | 3.1% | 71.9% |
| 2021 | 31 | 12.9% | 12.9% | 74.2% |
| 2022 | 47 | 17.0% | 19.1% | 63.8% |
| 2023 | 39 | 30.8% | 7.7% | 61.5% |
| 2024 | 44 | 15.9% | 6.8% | 77.3% |
| 2025 | 46 | 13.0% | 8.7% | 78.3% |
Evidence in granted and denied migraine decisions
For each kind of supporting evidence: how often the Board granted the migraine issue on the merits when the decision mentioned it, compared with decisions that did not. These are associations, not causes, and evidence is recorded per decision, not per issue.
| In the record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Positive nexus opinion | 83 | 92.6% | 26.6% | +66.0 pts |
| Private medical opinion | 127 | 79.7% | 29.6% | +50.1 pts |
| Favorable VA exam | 45 | 77.8% | 50.5% | +27.2 pts |
| Lay statement | 295 | 55.4% | 64.7% | −9.3 pts |
- The Board applied the benefit-of-the-doubt rule (38 CFR 3.102) in 76.1% of the decisions that granted migraine.
- The Board found the veteran's statements credible in 34.3% of grants and 13.7% of denials.
Negative evidence in the record
An unfavorable exam or a negative nexus opinion often sits in the same record as favorable evidence, and the Board weighs them against each other. So these rows show how often migraine was still granted when the record contained the negative item, not that the item helped.
| In the record | Decisions | Granted when present | When absent | Difference |
|---|---|---|---|---|
| Negative nexus opinion | 254 | 53.5% | 65.6% | −12.1 pts |
| Unfavorable VA exam | 301 | 53.1% | 72.7% | −19.6 pts |
Why the Board granted or denied migraine
Most common reasons in grants
- Caused by the service-connected disability10
- Current diagnosis established9
- Aggravated by the service-connected disability9
- Service connection established4
- Evidence evenly balanced2
Most common reasons in denials
- VA examiner: less likely than not related to service8
- Preponderance of the evidence against the claim6
- Aggravated by the service-connected disability5
- No in-service complaints, treatment or diagnosis4
- No direct service connection established2
- No current diagnosis2
- Criteria for service connection not met2
- Criteria for entitlement not met1
Numbers are decisions that gave the reason. Reasons are short phrases extracted by AI from each decision; common wordings of the same reason are grouped. Benefit of the doubt is reported above.
Recent migraine decisions
Granted
Approximate balance of evidence; Benefit of the doubt applied; Persuasive private treating physician opinions
Competent evidence establishes current diagnosis of tension headaches.; Veteran is service-connected for back disabilities.; Conflicting medical opinions (VA negative, private positive) created approximate balance, resolved in Veteran's favor.
Service connection granted as secondary to service-connected back disabilities.; Conflicting medical opinions (negative VA, positive private) resulted in approximate balance.; Benefit of the doubt applied to grant service connection.
Denied
No diagnosis of headaches during or after service; Unfavorable VA examiner opinion; Evidence persuasively weighs against claim
No in-service complaints, diagnosis, or treatment for headaches.; Veteran's statements in 2003 and 2017-2020 denied headaches.; Evidence weighed against secondary connection to lumbosacral strain.
August 2024 VA exam persuasive; No medical evidence linking headaches to herbicide exposure; Headaches unrelated to service-connected back disability
Rules that apply to secondary migraine claims
- 38 CFR 3.310
Secondary service connection and aggravation
Read it in VA Law Explorer - M21-1 V.ii.2.D
Secondary service connection and aggravation of non-service-connected disabilities
Read it in VA Law Explorer - 38 CFR 3.102
Reasonable doubt (benefit of the doubt)
Read it in VA Law Explorer - 38 CFR 4.124a · DC 8100
Schedule of ratings: neurological conditions
Read it in VA Law Explorer - M21-1 V.iii.12.A.3
Migraine: rating criteria, lay evidence of prostration, headache journals
Read it in VA Law Explorer - M21-1 IV.i.3.B.1.b
Reviewing a headache examination report
Read it in VA Law Explorer
Research your migraine case
Narrow by year, judge, evidence or secondary condition, read the decisions, and export a research memo.
How these numbers are calculated
- Counts decisions in which the Board decided a migraine issue claimed as secondary to a back condition, by the outcome of that issue.
- The primary disability is read from the decision text ("secondary to …") and grouped by name, so spellings such as "PTSD" and "posttraumatic stress disorder" count together.
- Secondary claims also include aggravation of a non-service-connected condition by a service-connected one (38 CFR 3.310(b)).
- The data comes from CaseScribe's AI extraction of public BVA decisions (2017–2026) and can contain errors. It is updated automatically as new decisions are added.